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Safety data sheet section 8: which value really applies?

Section 8 of the SDS lists exposure limits and DNELs, but not always the value that applies to your workplace. How to check them against current sources.

Saskia Houben
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Summary: Section 8 of the safety data sheet (SDS) lists the control parameters: occupational exposure limits, biological limit values and, for registered substances, DNELs. That is not always the value that applies at your workplace. The sheet may list another country’s values, be out of date, cover only some of the components, or show a DNEL where no limit exists. So check, for each component in section 3, the current statutory limit for your country, and where none exists choose the best available value using the limit-value hierarchy.

This article covers one part of the safety data sheet: which exposure limit applies to a substance. Three sections matter for that question: section 3 (which substances it contains, with CAS number and concentration), section 8 (which limits and DNELs the supplier lists) and, as a cross-check, section 2 (the classification and H-statements of the mixture). The other sections are outside the scope of this article.

What is in section 8?

The content of the SDS is set by Annex II of REACH, as amended by Regulation (EU) 2020/878. Section 8, Exposure controls / personal protection, has two parts:

  • 8.1 Control parameters. The national occupational exposure limits applicable in the member state where the product is placed on the market, with their legal basis; biological limit values; and for registered substances the DNELs (and PNECs for the environment).
  • 8.2 Exposure controls. Engineering controls and personal protective equipment.

For the exposure-limit question, 8.1 is the part that matters.

Why the value in the SDS is not always the value that applies

The sheet lists another country’s values. A supplier should list the values of the member state where the product is supplied, but in practice German, British or American values (such as the ACGIH TLV) often appear, especially on sheets written for several markets.

The sheet is out of date. National statutory limits change regularly; in the Netherlands, annex XIII of the Working Conditions Regulation is typically updated twice a year. An SDS is only revised when the supplier revises it, so a sheet that is a few years old can list a withdrawn or changed value.

Not every component has a value. Section 8 only lists substances for which the supplier knows a value. In mixtures containing petroleum fractions, reaction products and other UVCB substances, much of section 3 is often left without any limit.

A DNEL is not an exposure limit. DNELs appear in section 8 next to exposure limits, but they are derived by the registrant and have a different status. See the difference between a DNEL and an OEL.

How to check section 8 in four steps

  1. Take the components from section 3. Note the CAS number and concentration range of each substance. That is your substance list, not the selection that reappears in section 8.
  2. Look up the current statutory limit for each substance. For Dutch workplaces you can look up a limit value by CAS number: for annex XIII substances the number is shown with its source.
  3. No statutory limit? Follow the hierarchy. Look at health-based values from other countries or the EU, then at a DNEL, and if that is missing too, at a kick-off value. The order and the reasons are set out in the limit-value hierarchy.
  4. Record which value you use and why. In the risk assessment, note the value, its source and the date for each substance. If it differs from section 8, that is not your mistake, but it is worth documenting.

What DOHSBase does here

DOHSBase Online shows, per CAS number, the statutory limit next to health-based values from other countries, the DNELs and, where nothing else exists, a kick-off value, ranked by the hierarchy with the source alongside. Put the components of your products on a shortlist and you are also notified when a limit value or classification of any of those substances changes. That keeps your substance list current, even when the safety data sheet is not.

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Frequently asked questions

Is an exposure limit in the safety data sheet binding?
No. The safety data sheet does not set a limit; it passes on the values the supplier knows. For a workplace, the statutory limit of the country where the work takes place applies, even if the sheet lists a different or older value.
What if section 8 lists no exposure limit?
Not necessarily that no limit exists: the sheet may be incomplete, out of date, or list only another country’s values. So first look up the current statutory limit yourself. If there really is none, that still does not mean the substance is safe. In the Netherlands the employer then sets its own limit (a private limit value) and records the basis, for example from a health-based limit in another country, a DNEL or a kick-off value; other countries have their own rules.
Can I use a DNEL from the safety data sheet as an exposure limit?
A DNEL is a value the registrant derived under REACH; it is not a statutory limit. Where no limit exists it can be a useful starting point, but weigh how and by whom it was derived, and record that.